On 23 October, the European Council adopted a new framework for restrictive measures against Niger which seek to “sanction those who undermine the stability, democracy, rule of law in Niger, and constitute a threat to peace and security in the region” in response to the July 2023 military coup in Niger.

The sanctions consist of asset freezes, and the related prohibition to make funds available to targeted individuals and entities, as well as travel bans for certain individuals. In addition, and in order to further humanitarian aid efforts, a humanitarian exception to the asset freeze measures has also been established.

This autonomous framework is contained within Council Decision (CFSP) 2023/2287 (the “Decision”) and Council Regulation (EU) 2023/2406 (the “Regulation”). As of 24 October 2023, no people or entities have yet been designated under these restrictions, per Annex I of this Decision and Regulation. Once designated parties have been added, companies will need to be mindful of Niger as part of their overall screening program.

Author

Sunwinder (Sunny) Mann is a Partner and is Chair of our International Commercial and Trade Global Practice Group. Our Trade team has been ranked Tier 1 by Legal 500 UK for over 20 years. He is currently based in our London office, but has also worked in our offices in Washington, D.C., New York, Sydney and Hong Kong. Sunny's practice focuses on international trade compliance and, in particular, export controls and trade sanctions, as well as anti-bribery. He has worked on a number of significant compliance and investigations matters. He leads our Firm's Geopolitical Risks Taskforce, having coordinated our Firm's support to clients responding to the ongoing Russia crisis.